Justia Montana Supreme Court Opinion Summaries

Petitioner Emily Blodgett petitioned the Supreme Court for a Writ of Supervisory Control alleging that the Missoula County Justice Court violated sections 3-10-231 through -234, MCA; Article VII Sections 1 and 5 of the Montana Constitution, and several of the Court's prior decisions when it allowed a retired district court judge to preside over her jury trial. Petitioner contended that the presiding justice of the peace improperly called the judge to preside over the case even though the justice was present in her court but otherwise involved with another case. Finding that though the retired judge was qualified by his training and experience to act as a substitute justice of the peace, he was not one at the time he presided over Petitioner's trial because the statutory procedures to vested him with the power to perform judicial functions as a substitute justice of the peace had not been followed. Consequently, any purported judicial acts performed by the judge in this case were void ab initio. The Supreme Court granted Petitioner's request for a Writ of Supervisory Control and held that Petitioner's jury trial was void ab initio. The case was remanded for further proceedings. View "Blodgett v. Missoula JP Court" on Justia Law

At issue in this case was the Montana Board of Oil & Gas Conservation's (MBOGC) issuance of twenty-three gas well permits to Fidelity Exploration and Production Company in the area known as the Cedar Creek Anticline (CCA). The Montana Wildlife Federation and National Wildlife Federation (collectively, Federations) challenged the issuance of the permits. The district court granted summary judgment in favor of Appellees, MBOGC, Fidelity, and Montana Petroleum Association, holding that the Federations failed to rebut the presumption of validity in the MBOGC's decision. The Supreme Court affirmed, holding that the district court did not err in (1) conducting its review under Mont. Code Ann. 82-11-144 and in considering evidence outside the administrative record; (2) determining that the environmental assessments prepared by MBOGC for gas development in the CCA were adequate under the Montana Environmental Policy Act; and (3) ruling that MBOGC did not have to prepare a programmatic environmental impact statement for oil and gas development in the CCA. View "Mont. Wildlife Fed'n v. Bd. of Oil & Gas Conservation" on Justia Law

Oliver Arlington was employed by Miller's Trucking as a log truck driver and loader operator pursuant to an oral employment agreement. For his work, Miller's paid Arlington twenty-five percent of the "load rate" as calculated by Miller's. Arlington, however, asserted that according to the parties' oral agreement, he should have been paid a salary in the form of annual wages. Arlington filed a wage claim, seeking the pay he alleged he was owed in regular and overtime wages. The Department of Labor and Industry's bureau dismissed Arlington's claim for lack of merit and lack of sufficient evidence. On appeal, a bureau hearing officer dismissed Arlington's claim. The district court affirmed. The Supreme Court reversed, holding (1) the hearing officer acted arbitrarily and capriciously in failing to require Miller's to produce material requested by Arlington and in refusing to admit tendered evidence, prejudicing the substantial rights of Arlington, and the district court erred in affirming the hearing officer's judgment; and (2) the hearing officer and district court incorrectly determined that Arlington engaged in activities of a character directly affecting the safety of the operation of motor vehicles in interstate commerce and thus was exempt from overtime requirements. Remanded. View "Arlington v. Miller's Trucking, Inc." on Justia Law

The Town filed an application with the Montana Department of Natural Resources and Conservation (DNRC) seeking approval for proposed changes to its municipal well water rights. The DNRC notified the Town that its application was deficient because it did not contain information on the Town's historical use of its rights. The Town did not provide the information, contending that the information was irrelevant to its application. The DNRC then determined that the Town's application was not correct and complete as required by Mont. Code Ann. 85-2-302 and informed the Town that its application was terminated. The district court upheld the DNRC's decision. The Supreme Court affirmed, holding that, based on established Montana law and the applicable regulations, the DNRC was within its lawful authority to request that the Town provide information on its historical use of water as part of its application for approval of its proposed changes. View "Town of Manhattan v. Dep't of Natural Res. & Conservation" on Justia Law

Employee, a truck driver, resigned from his employment with Employer after he developed arthritis. Employee later filed an occupational disease claim, which the Montana State Fund (MSF) denied. The Workers' Compensation Court (WCC) concluded that Employee's job duties were the major contributing cause of his arthritic condition, and therefore, Employee was suffering from an occupational disease. The Supreme Court affirmed, holding that the WCC did not err in concluding that Grande was suffering from a compensable occupational disease arising out of and in the course and scope of his employment, as the WCC's findings of fact were supported by substantial, credible evidence, and its conclusions of law were correct. View "Mont. State Fund v. Grande" on Justia Law

Appellants, a group of individuals, filed a complaint with the Montana Public Service Commission (PSC) against NorthWestern Energy (NWE) concerning NWE's provision of street lighting services. The PSC dismissed the complaint on the ground that the four named complainants lacked standing under Mont. Code Ann. 69-3-321. Appellants then filed an amended complaint in which they named four additional complainants. The PSC concluded (1) Appellants were procedurally barred from amending their complaint, and (2) the court would not reconsider its earlier ruling on standing in any event. The district court affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the original complainants lacked standing to pursue their complaint in the PSC under section 69-3-321; but (2) the PSC's and district court's rationales for rejecting the amended complaint were incorrect as, in this case, there was not a categorical procedural bar to the filing of an amended complaint following an order of dismissal for lack of standing. View "Williamson v. Mont. Pub. Serv. Comm'n" on Justia Law

Randall Simms was injured during his employment. The Montana State Fund (MSF) provided workers compensation to Simms' employer, and later, paid continuing medical benefits for Simms. MSF subsequently utilized the services of a special investigative unit (SIU) to investigate Simms for fraud. The SIU took multiple videos of Simms in public places. The videos were deemed confidential criminal justice information (CCJI) by the district court. The court allowed them to be used in relation to Simms' workers' compensation claim in any manner consistent with the Montana Rules of Civil Procedure and workers' compensation court (WCC) procedures. Simms appealed, arguing that MSF did not having standing to file an action for dissemination under the Montana Criminal Justice Information Act of 1979, and that the district court inadequately balanced the demands of individual privacy against the merits of disclosure, did not follow established rules of statutory construction, and improperly identified and weighed the competing interests at issue. The Supreme Court affirmed, holding that the court did not err when it authorized MSF to disseminate the CCJI under the Act, and the court correctly interpreted the statute and adequately engaged in the statutorily mandated balancing of competing concerns. View "Mont. State Fund v. Simms" on Justia Law

The City of Dillon entered an agreement with the McNeills allowing them to connect to a water main for their domestic water supply. Later, the City granted permission to the McNeills to activate an existing water service to their property. The Conners bought the McNeills' subdivided lot, and the City billed and collected for the water that was furnished to the Conners. The water main subsequently froze solid, leaving the Conners without water service for weeks. The Conners sued the City for breach of contract and negligence. The district court entered summary judgment for the City, concluding (1) there was no implied contract between the Conners and the City, and therefore, the Conners' water use was unlawful; and (2) the negligence claim was barred by City Ordinance 13.04.150, which provides that the City is not liable for claims from interruption of water service resulting from shutting off the water in its mains. The Supreme Court reversed, holding (1) the City had a legal obligation to provide water to the Conners under an implied contract; and (2) section 13.04.150 did not bar the Conners' claims because the City did not decide to shut off the water service. View "Conner v. City of Dillon" on Justia Law

James Whealon was employed by the Anaconda School District pursuant to a series of employment contracts. Upon retirement, Whealon filed a formal grievance, asserting that, under the terms of his contract, he was entitled to payment of his health insurance premiums by the District until he reached the age of sixty-five. The District denied his claim. The County Superintendent granted summary judgment to the District, holding that the language of the contract was unambiguous and that Whealon was not entitled to the claimed benefits beyond the date of his retirement. The State Superintendent of Public Instruction reversed and remanded for an evidentiary hearing, holding that the language of the contract was ambiguous. The district court reversed and reinstated the County Superintendent's ruling. The Supreme Court affirmed the district court, holding (1) the district court did not err in holding that a county superintendent has authority to grant summary judgment; and (2) the district court did not err in reinstating summary judgment in favor of the district where the language of the agreement was unambiguous and the District was entitled to judgment. View "Anaconda Public Schools v. Whealon" on Justia Law

Hobble Diamond Ranch, Robert and Susan Burch, and James Lowe, (collectively, Neighbors), appealed the district court's judgment affirming the Montana Department of Transportation's (DOT) decision to issue billboard sign permits under the Montana Outdoor Advertising Act. Neighbors sought removal of two billboards, arguing that the billboards were not in compliance with MOAA, DOT's granting of the permits was unlawful, and the billboards were a public nuisance. The Supreme Court affirmed, holding that the district court's ruling upholding the DOT decision was not arbitrary capricious, or unlawful, as the permit applications were in conformance with MOAA and DOT based its decision on sufficient evidence. View "Hobble Diamond Ranch v. State ex rel. Dep't of Transp." on Justia Law